2015 Modification Assessment Cost and Accounting Report March 1, 2017

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1 2015 Modification Assessment Cost and Accounting Report March 1, 2017 Prepared by: Raeann Quadro California Independent System Operator

2 Table of Contents 1. Executive Summary 1.1. Purpose and Scope 1.2. Background 1.3. Process Modification Assessment Cost and Accounting Report 2.1 Cost 2.2 Timing 2.3 Outcomes 3. Comparison to 2014 Results Doc ID: XWK2E22ZZR Page 1 of 10

1.0 Executive Summary 1.1 Purpose and Scope The CAISO evaluates a variety of modification requests for Interconnection Customers generator projects.

3 1.0 Executive Summary 1.1 Purpose and Scope The CAISO evaluates a variety of modification requests for Interconnection Customers generator projects. In doing so, the CAISO coordinates with the relevant Participating TO(s) and Affected System Operator(s), if any. Effective December 3, 2013, the CAISO Tariff requires that Interconnection Customers themselves bear the costs of these modification assessments. To provide transparency, the Tariff also requires the CAISO to publish cost data for modification assessments. This report contains a description of the number, types, duration, and costs of modification requests completed in Background The CAISO generally uses the same process and criteria to review modification requests for all generation projects. 1 A high level-depiction of the modification process is below: Customers are required to provide a $10,000 deposit for the modification assessment, and after the modification assessment is complete, the CAISO invoices for the actual costs of the modification assessment. The invoices include an itemized account of expenses incurred, including those incurred by the CAISO, the Participating TOs, and third parties at the direction of the CAISO or Participating TO). Whenever the actual cost of performing the modification assessment exceeds the modification assessment deposit, the invoice directs the Interconnection Customer to pay the excess amount. However, it is far more common for the deposit to exceed the invoice, 2 in which case the Interconnection Customer is refunded the balance. 1 The modification assessments discussed in this report are governed by CAISO Tariff Appendix S, Section 1.3.4; Appendix T, Section 3.4.5; Appendix U, Section 4.4.3; Appendix Y, Section ; or Appendix DD, Article as applicable, and the BPM for Generator Management. 2 Or the Interconnection Customer withdraws its modification request before most costs are incurred. Doc ID: XWK2E22ZZR Page 2 of 10

4 1.3 Process Types of Modifications The Interconnection Customer must submit to the CAISO, in writing, a request to modify any information provided in the Interconnection Request. 3 The variety, content, and scope of modification requests are as unique and complex as the Generating Facilities themselves, but for the purpose of this report, modification requests have been grouped into three buckets : 1) Commercial Operation Date ( COD ) extensions and/or requests for project Phasing; 2) Technology changes, e.g., inverter, transformer, and equipment changes; and 3) Interconnection changes, e.g., generation tie route changes, Point of Interconnection changes, Point of Change of Ownership Changes, and Site Location changes. Time The modification assessment commences when the CAISO and Participating TO (1) deem the modification request (including all of the necessary technical documents) valid and data complete, and (2) receive the Interconnection Customer s modification assessment deposit. Per the Tariff, the CAISO targets providing a written response to the Interconnection Customer within 45 days of commencement. If the modification assessment cannot be completed within that period, the CAISO notifies the Interconnection Customer and provides an estimated completion date and explains why additional time is required. 3 Please note that, inter alia, requests to increase the maximum output of a project are not permitted in the modification process. Doc ID: XWK2E22ZZR Page 3 of 10

5 Modification Assessment Cost and Accounting Report 2.1 Cost The CAISO completed 54 modification assessments in The average cost for a modification assessments in 2015 was $4, The highest cost modification assessment was $28, The lowest cost modification assessment was $ Average cost per type was as follows: $9,000 $8,000 $7,000 $6,000 $5,000 $6,923 $4,781 $5,905 $7,783 COD COD & Technology COD, Technology & Interconnection $4,000 $3,000 $2,000 $1,707 $3,220 Interconnection Technology Technology & Interconnection $1,000 $0 4 The CAISO tariff requires that The Participating TO(s) shall invoice the CAISO for any assessment work within seventy-five (75) calendar days of completion of the assessment. These values include modification assessments where the ISO received no invoice from the Participating TO. Doc ID: XWK2E22ZZR Page 4 of 10

6 2.2 Timing The average time for the 54 modification assessments completed in 2015 was 50 days. This number is representative of the time between the day the modification request is considered complete (request and deposit are received, and technical data is clear of deficiencies) and the day the CAISO sent the results letter. The quickest modification assessment was completed in 7 days. The longest modification assessment was 120 days. The average time for COD modifications by type was as follows: COD 80 COD & Technology COD, Technology & Interconnection Interconnection Technology Technology & Interconnection 20 0 Doc ID: XWK2E22ZZR Page 5 of 10

7 2.3 Outcomes Of the 54 modification assessments completed in 2015, 26 were approved, 21 were conditionally approved, 2 were partially approved, 5 and 5 were denied. Approved Denied Partially Approved Conditionally Approved Conditional approval was generally based on the following conditions: Execute the Generator Interconnection Agreement within a certain period. Continue to make payments and postings for Network Upgrades. Propose different CODs from the request due to Participating TO construction times. For storage devices, respond to CAISO dispatch, a mechanism in place to ensure that the project does not deliver more to the CAISO controlled grid than studied, and separate metering and telemetry. For inverter changes, install a mechanism to ensure that the project does not deliver more to the CAISO controlled grid than studied. Requests were partially approved for the following reasons: The project requested a COD change and an interconnection change in a single MMA, and the interconnection portion of the request was denied because the proposed change significantly increased the project s short circuit duty contributions. The project requested a COD extension beyond the 7 year threshold and did not provide sufficient justification to go beyond the 7 year threshold. However, CAISO and the PTO were able agree to a COD extension up to the 7 year threshold. 5 One or more components of a multi-part request was denied. Doc ID: XWK2E22ZZR Page 6 of 10

8 Requests were denied for the following reasons: Two COD extensions were denied because the transmission upgrades and interconnection facilities required to interconnect the project were on track to meet the project s approved In-Service Date, and the project did not provide sufficient justification for a COD extension beyond the 7/10 year thresholds. The MW increase to the Project gross capacity caused by the proposed inverter change was greater than the ten percent (10%) allowed under the CAISO s modification assessment process. Two POI change requests were denied because the addition of a direct tap to the proposed line would have compromised reliability of the grid. Doc ID: XWK2E22ZZR Page 7 of 10

9 3.0 Comparison to 2014 Results The following tables compare data presented in this report to the 2014 Modification Assessment Cost and Accounting Report. Timing comparisons to 2014 are provided, however, it is important to note that the 2014 figures may be unrepresentative of the CAISO s current process because the CAISO formerly tracked when the request arrived and not when the data for the request was complete. As such, the times from the 2014 data set are inflated. Time (calendar days) Overall High Low 10 7 Average COD Average COD & Technology Average COD, Technology & Interconnection Average Interconnection Average Technology Average Technology & Interconnection n/a High-Low-Average MMA Time in Calendar Days High Low Average Doc ID: XWK2E22ZZR Page 8 of 10

10 Costs Overall $2, $4, High $14, $28, Low $29.75 $68.00 Average COD $1, $1, Average COD & Technology $1, $6, Average COD, Technology & Interconnection $6, $3, Average Interconnection $8, $4, Average Technology $2, $5, Average Technology & Interconnection n/a $7, $35, $30, $25, $20, $15, $10, $5, High-Low-Average MMA Cost $ High Low Average 6 The cost of this MMA is an anomaly, the next highest cost MMA was $15, Doc ID: XWK2E22ZZR Page 9 of 10

11 Outcomes Approved 30 32% 26 48% Denied 2 2% 5 9% Partially Approved 1 1% 2 4% Conditionally Approved 61 65% 21 39% Grand Total % MMA Outcomes by Year 65% 60% 50% 48% 40% 39% 32% 30% 20% 10% 0% 9% 4% 1% 2% Approved Conditionally Approved Partially Approved Denied Doc ID: XWK2E22ZZR Page 10 of 10

2014 Modification Assessment Cost and Accounting Report July 1, 2015

2014 Modification Assessment Cost and Accounting Report July 1, 2015 Prepared by: Raeann Quadro Version: 1 California Independent System Operator Table of Contents 1. Executive Summary 1.1. Purpose and